Universal Legal Justification: Do The Inspired Writings Teach It?

For a number of years now, a theory known as “universal legal justification” has been making the rounds among devout Seventh-day Adventists. 

In short, this theory teaches that on Calvary’s cross, Jesus didn’t simply die for the whole human race—something we all believe—thus providing for all a way of salvation should they meet the prescribed conditions found in Scripture. Rather, this “universal justification” theory insists that Christ legally justified the whole human race when He died on Calvary. 

One prominent advocate of this teaching in contemporary Adventism states as follows:

I believe the Bible teaches that God actually and unconditionally saved all humanity at the cross so that we are justified and reconciled to God by that act (see Romans 5:10,18; 2 Corinthians 5:18,19). I believe that the only reason anyone will be lost is because he or she willfully and persistently rejects God’s gift of salvation in Christ (see John 3:18,36) (1).

Elsewhere he writes:

The gospel is the unconditional good news of salvation for all mankind (2).

The difference between this doctrine and the classic Adventist doctrine of salvation is the simple difference between accomplishing and providing. The doctrine of universal legal justification says Jesus actually accomplished everyone’s salvation at Calvary, whether they meet the conditions found in the Bible or not. Unless one takes affirmative action to resist and reject this salvation, so the theory goes, it remains legally intact. The classic Adventist doctrine of salvation, by contrast, teaches that Christ has provided salvation for all, but that this salvation can only become real—legally or otherwise—if the conditions found in God’s Word are fulfilled. 

Illustrating the contrast between these two doctrines is easy. The classic Adventist view is comparable to a man asking a woman to marry him, giving her the choice to either accept or reject his proposal. The doctrine of universal legal justification, by contrast, is comparable to a man announcing to that same woman that he and she are legally married already, and that unless she goes to the courthouse and files for divorce, the marriage remains legally intact.

Which of these two doctrines is taught in the Bible? Which of the two is taught in the writings of the Spirit of Prophecy?

We need to examine the evidence.

The Message of Romans 5

The cornerstone of the doctrine of universal legal justification, according to its promoters, is the parallel between Adam and Christ drawn by the apostle Paul in the fifth chapter of Romans. Since the entire passage is important in the consideration of the issue at hand, it is quoted in full below:

Wherefore, as by one man sin entered into the world, and death by sin, and so death passed upon all men, for that all have sinned. For until the law sin was in the world: but sin is not imputed where there is no law. Nevertheless death reigned from Adam to Moses, even over them that had not sinned after the similitude of Adam’s transgression, who is the figure of Him that was to come. But not as the offense, so also is the free gift.  For if through the offense of one many be dead, much more the grace of God, and the gift be grace, which is by one man, Jesus Christ, hath abounded unto many. And not as it was by one that sinned, so is the gift: for the judgment was by one to condemnation, but the free gift is of many offenses unto justification. For if by one man’s offense death reigned by one: much more they which receive abundance of grace and of the gift of righteousness shall reign in life by one, Jesus Christ. Therefore as by the offense of one judgment came upon all men to condemnation; even so by the righteousness of one the free gift came upon all men unto justification of life. For as by one man’s disobedience many were made sinners, so by the obedience of one shall many be made righteous.

Three points, among others, stand out in these verses:

1.  Life and death, as described in this passage, are primarily eternal rather than temporal. This becomes clearest in verse 17, which speaks of how those “which receive abundance of grace and of the gift of righteousness shall reign in life by one, Jesus Christ.” Obviously this refers to the future eternal reign of the saints with Christ (Rev. 5:10). Elsewhere in Romans Paul, when speaking of life and death in a spiritual sense, refers to eternal rather than temporal reality (Rom. 8:13). Here Paul uses this language in the same way as Jesus, who declared to the rich young ruler, “If thou wilt enter into life, keep the commandments” (Matt. 19:17; see also Luke 10:28).     

So when Romans 5:12 speaks of death passing upon all men, temporal death (though certainly real) is not the main focus. The claim of some that newborn babies must be sinners because they experience physical death is obviously exploded by the fact that animals experience such death as well.

2.  The phrases “judgment came” and “the free gift came,” found in verse 18, are supplied, which is why the King James Version places them in italics. This is especially significant because this verse is often the cornerstone of the claim that both Adam’s condemnation and Christ’s justification have been accomplished for all, whether they like it or not. But without these added phrases, it is easier to harmonize this verse with others in this passage which indicate the decisive role of choice in making real the occurrence of both sin and salvation. 

3.  Three verses in this passage make it clear that whatever the role played by Adam and Christ in the human saga, free choice is what makes humans either condemned sinners or justified saints. Regarding condemnation, Romans 5:12 declares that “death passed upon all men, for that all have sinned.” Notice it doesn’t say death (eternal) has passed on all men because Adam sinned, but rather, because all have sinned.   

The same holds true for justification. Paul states that the ones justified are those who “receive abundance of grace and of the gift of righteousness” (verse 17, italics supplied). Verse 19 clarifies the same point, which declares that “as by one man’s disobedience many were made sinners, so by the obedience of one shall many be made righteous.” Obviously, just as the many being made sinners has occurred because “all have sinned” (verse 12), so the many being made righteous is here depicted as a future event determined by the choice of individuals, not a past event occurring once for all time at the cross.   

The theme of Romans 5 is really quite simple: Adam led the world into sin, and Christ has offered to lead us out of it. But just as the choice to sin is ours, so is the choice to accept Christ’s righteousness. No involuntary verdict of condemnation or justification is taught in this passage. 

The Biblical Conditions for Divine Forgiveness

God’s forgiveness, or justification, is consistently described in Scripture as dependent on the divinely-empowered fulfillment of certain conditions by the sinner. Confession of sin, the forsaking of sin, together with our willingness to forgive those who have wronged us, are listed in the Bible as prerequisites for the divine pardon of human sin:

If My people, which are called by My name, shall humble themselves, and pray, and seek My face, and turn from their wicked ways, then will I hear from heaven, and will forgive their sins, and heal their land (II Chron. 7:14).

He that covereth his sins shall not prosper, but whoso confesseth, and forsaketh them shall have mercy (Prov. 28:13).

Let the wicked forsake his way, and the unrighteous man his thoughts, and let him return unto the Lord, and He will have mercy upon him; and to our God, for He will abundantly pardon (Isa. 55:7).

For if ye forgive men their trespasses, your heavenly Father will also forgive you. But if ye forgive not men their trespasses, neither will your Father forgive your trespasses (Matt. 6:14-15).

For not the hearers of the law are just before God, but the doers of the law shall be justified (Rom. 2:13).

If we confess our sins, He is faithful and just to forgive us our sins, and to cleanse us from all unrighteousness (I John 1:9).

Notice how, in the following statements, Ellen White draws a contrast between God’s calling the sinner to repentance and forgiveness, and the actual act of pardon, which she defines as justification:

Pardon and justification are one and the same thing (3).

Calling and justification are not one and the same thing. Calling is the drawing of the sinner to Christ, and it is a work wrought by the Holy Spirit upon the heart, convicting of sin, and inviting to repentance (4).

The same author defines repentance as follows:

Repentance includes sorrow for sin, and a turning away from it (5).

This sorrow, this turning, is imperative as a prerequisite for the experience of Biblical justification. The following statements, considered earlier in our study, affirm this point with unmistakable clarity:

When through repentance and faith we accept Christ as our Saviour, the Lord pardons our sins, and remits the penalty prescribed for the transgression of the law (6).

Christ pardons none but the penitent, but whom He pardons He first makes penitent.  The provision made is complete, and the eternal righteousness of Christ is placed to the account of every believing soul (7).

God requires the entire surrender of the heart, before justification can take place (8).

God will soon vindicate His justice before the universe. His justice requires that sin shall be punished; His mercy grants that sin shall be pardoned through repentance and confession. Pardon can come only through His only begotten Son; Christ alone can expiate sin—and then only when sin is repented of and forsaken (9).

The unconditional pardon of sin never has been, and never will be (10).

There is no salvation without repentance (11).

Let none say that there are no conditions to salvation. There are decided conditions, and everyone is put to the strenuous task of diligently inquiring and searching for the truth from God’s Word. At the peril of our souls we must know the prescribed conditions given by Him who has given His own life to save us from ruin (12).

The reason God’s forgiveness can’t be unconditional is because it produces a direct, internal change in the one being forgiven. Too many of us think of God’s forgiveness is analogous to human forgiveness, the latter being in most cases the letting go of a grudge. God’s forgiveness, by contrast, involves not only a legal transaction on God’s part, but also the removal of sin from the heart of the penitent believer. Thus Ellen White declares:

God’s forgiveness is not merely a judicial act by which He sets us free from condemnation. It is not only forgiveness for sin, but reclaiming from sin. It is the outflow of redeeming love that transforms the heart. David had the true conception of forgiveness when he prayed, ‘Create in me a clean heart, O God, and renew a right spirit within me.’ Psalm 51:10 (13).

This explains why God’s forgiveness, or justification, can never be accomplished for anyone apart from the voluntary surrender of the will and the repudiation of sinful practices. God can’t remove from us what we choose to keep. The safeguarding of creaturely choice is central to the plan of salvation and the successful divine prosecution of the struggle with evil. Ellen White makes the following, very strong statement regarding free will and its role in salvation:

The Lord Jesus came to our world full of mercy, life, and light, ready to save those who should come unto Him. But He can save no one against his will. God does not force the conscience. . . All this work is after the order of Satan (14).

Reconciled to God

But, someone asks, doesn’t the Bible say that the whole world was reconciled to God when Jesus died on the cross?

It is true that a number of New Testament passages speak of the cross as the means whereby we are reconciled to God. But a close look at each of them makes it clear that the theme in these verses is instrumental, not chronological. Let us examine each of these passages:

For if, when we were enemies, we were reconciled to God by the death of His Son, much more, being reconciled, we shall be saved by His life (Rom. 5:10).     

And all things are of God, who hath reconciled us to Himself by Jesus Christ, and hath given to us the ministry of reconciliation; to wit, that God was in Christ, reconciling the world unto Himself, not imputing their trespasses unto them, and hath committed unto us the word of reconciliation. Now then we are ambassadors for Christ, as though God did beseech you by us; we pray you in Christ’s stead: be ye reconciled to God (2 Cor. 18-20).

And, having made peace through the blood of His cross, by Him to reconcile all things unto Himself; by Him, I say, whether they be things on earth, or things in heaven. And you, that were sometime alienated and enemies in your mind by wicked works, yet now hath He reconciled in the body of His flesh through death, to present you holy and unblameable and unreprovable in His sight: if ye continue in the faith grounded and settled, and be not moved away from the hope of the gospel (Col. 1:20-23). 

Notice that while Paul says in one place, “We were reconciled to God by the death of His Son” (Rom. 5:10), and in another that God “hath reconciled us to Himself by Jesus Christ” (II Cor. 5:18), he invites his readers elsewhere, “Be ye reconciled to God” (II Cor. 5:20). Obviously the first two statements refer to converted believers, while the third is an invitation to readers who are not yet converted. 

Paul’s earlier statement in II Corinthians 5 that “we commend not ourselves again unto you, but give you occasion to glory on our behalf” (verse 12), gives further evidence that “we” refers to himself and his fellow evangelists who had experienced God’s converting power, while “you” refers to his audience which doubtless included many who had not experienced conversion. 

The verse in Romans which states that “when we were enemies, we were reconciled” (Rom. 5:10) must be placed alongside the verses we read from Colossians 1, which states that “you, that were sometime alienated and enemies in your mind by wicked works, yet now hath He reconciled” (verse 21). The fact that this is individual rather than universal is even clearer in the following verses, where Paul speaks of the reconciliation process including Christ presenting us “unblameable and unreprovable in His sight: if ye continue in the faith grounded and settled, and be not moved away from the hope of the gospel” (verses 22-23). These verses clearly speak of those who have relinquished their evil deeds by availing themselves of Calvary’s reconciling power. Without question this cannot refer to the whole world, but includes only to those who have willingly chosen by God’s grace to give up their sins. 

We must also notice that II Corinthians 5:19, which speaks of the world as the focus of reconciliation, uses the word reconciling—which is in the present, continuous tense.  Never does Paul say the world has been reconciled (past tense). The verse also says, “not imputing their trespasses unto them.” But when Paul writes elsewhere of those to whom the Lord does not impute iniquity, he quotes an Old Testament passage which adds a condition to this—“in whose spirit there is no guile” (Psalm 32:2). Again, this can’t possibly refer to the whole world, only to those who by God’s grace meet the conditions for receiving pardon.   

Elsewhere the New Testament is clear that the work of Christ as high priest in heaven is “to make reconciliation for the sins of the people” (Heb. 2:17). This is why the apostle John assures us, “If any man sin, we have an advocate with the Father, Jesus Christ the righteous” (1 John 2:1).  Notice he doesn’t say, “We have a Savior who died on Calvary.” The process of receiving forgiveness is the same in the New Testament as in the Old.  Confession of sin, the forsaking of sin, and the mediation of sacrificial blood remain clearly-stated conditions (Lev. 4,5; Matt. 6:14-15; Rom. 2:13; 1 John 1:9). The only difference between the portrayal of this process in the two Testaments is that in the Old there were many sacrifices, many priests, and an earthly sanctuary, whereas in the New there is one Sacrifice, one Priest, and a heavenly sanctuary.   

The following Ellen White statements confirm what we have seen from Scripture—that human reconciliation to God through Christ’s blood is an individual matter, conditional on confession, repentance, and the Spirit’s transforming power:

You have seen that all who come to Me, confessing their sins, I freely receive. Him that cometh to Me, I will in no wise cast out. All who will, may be reconciled to God, and receive everlasting life (15).

It is the work of conversion and sanctification to reconcile men to God by bringing them into accord with the principles of His law (16).

It is by the law of God that the sinner is convicted. He sees his own sinfulness in contrast with the perfect righteousness which it enjoins, and this leads him to humility and repentance. He becomes reconciled to God through the blood of Christ (17).

By the atoning sacrifice of Christ, and His work of mediation in our behalf, we may become reconciled to God. The blood of Christ will prove effacacious to wash away the crimson stain of sin (18). 

The following statement is perhaps clearest of all that the reconciliation Calvary provides is not an involuntary act accomplished for the whole world, believers and unbelievers alike:

To him who accepts Christ as his righteousness, as his only hope, pardon is pronounced; for God was in Christ reconciling the world unto Himself. The justice, truth, and holiness of Christ, which are approved by the law of God, form a channel through which mercy may be communicated to the repenting, believing sinner. Those who do not believe in Christ are not reconciled to God; but those who have faith in Him are hid with Christ in God (19).

The “In Christ” Motif

The theory of universal legal justification includes what many have called the “in Christ” motif—the idea that the whole world was legally “in Christ” when He died on the cross. But again, this teaching stands seriously at odds with a number of very clear Bible statements which use this phrase:

Therefore if any man be in Christ, he is a new creature; old things are passed away, behold all things are become new (II Cor. 5:17).

Yea doubtless, and I count all things but loss for the excellency of the knowledge of Christ Jesus my Lord: for whom I have suffered the loss of all things, and do count them but dung, that I may win all things, And be found in Him, not having mine own righteousness, which is of the law, but that which is through the faith of Christ, the righteousness which is of God by faith (Phil. 3:8-9).

Salute Andronicus and Junia, my kinsmen, and my fellow prisoners, who are of note among the apostles, who also were in Christ before me (Rom. 16:7).

He that eateth My flesh, and drinketh My blood, dwelleth in Me, and I in him (John 6:56).

But whoso keepeth His word, in him verily is the love of God perfected: hereby know we that we are in Him (I John 2:5).

And he that keepeth His commandments dwelleth in Him, and He in him (I John 3:24).

Whosoever shall confess that Jesus is the Son of God, God dwelleth in him, and he in God. And we have known and believed the love that God hath to us. God is love, and he that dwelleth in love dwelleth in God, and God in him (I John 4:15-16).

None of these verses offer the slightest hint that anyone is, or has been, legally “in Christ” because of the cross event. To be “in Christ,” according to these passages, is to be “a new creature” (II Cor. 5:17), to keep God’s commandments (I John 3:24), to eat the flesh and drink the blood of the Son of God (John 6:56), and to confess Jesus’ divinity (I John 4:15-16). Not a single inspired statement, in either Scripture or the writings of Ellen White, declares anyone to be “in Christ” involuntarily because of Calvary, without first meeting the Biblical conditions stated above.

What In Fact Jesus Accomplished for the Whole World

There are those who will cite the following inspired statements as proof that the whole world was justified by Jesus on His cross:

He (Christ) took in His grasp the world over which Satan claimed to preside as his lawful territory, and by His wonderful work in giving His life, He restored the whole race of men to favor with God (20).

Man sold himself to Satan, but Jesus bought back the race (21).

Christ died for every man. He has ransomed every man by giving His life on the cross (22).

What do these statements mean, if they don’t refer to universal legal justification? To understand these passages, we need to retrace the history of the great controversy back to the fall of our first parents in Eden. 

When Adam and Eve sinned, Satan became the official representative of this world. This is why we find him at the committee table in heaven during the story of Job, representing Planet Earth (Job 1:6-7; 2:1-2). Ellen White explains in the following statement how the sacrifice of Jesus on Calvary recovered this lost dominion:

At his creation, Adam was placed in dominion over the earth. But by yielding to temptation, he was brought under the power of Satan. ‘Of whom a man is overcome, of the same is he brought in bondage.’ II Peter 2:19. When man became Satan’s captive, the dominion which he held, passed to his conqueror. Thus Satan became ‘the god of this world.’  II Cor. 4:4. He had usurped that dominion over the earth which had been originally given to Adam. But Christ, by His sacrifice paying the penalty of sin, would not only redeem man, but recover the dominion which he had forfeited (23).

When Adam and Eve sinned, they should have died that instant (Gen. 2:17). The only reason they didn’t is because Jesus stepped in, and gave them and their descendants another trial. The following Ellen White statements explain this:

Adam and his companion were assured that notwithstanding their great sin, they were not to be abandoned to the control of Satan. The Son of God had offered to atone, with His own life, for their transgression. A period of probation would be granted them, that through repentance, and faith in Christ they might again become the children of God (24).

Christ bore the sins of the world in man’s behalf that the sinner might have another trial, with all the divine opportunities and advantages which God has provided in man’s behalf (25).

This was the position of the human race after man divorced himself from God by transgression. Then he was no longer entitled to a breath of air, a ray of sunshine, or a particle of food. And the reason why man was not annihilated was because God so loved him that He made the gift of His dear Son that He should suffer the penalty of his transgression. Christ proposed to become man’s surety and substitute, that man, through matchless grace, should have another trial—a second probation—having the experience of Adam and Eve as a warning not to transgress God’s law as they did (26).

This is why, in another statement, Ellen White speaks of how the cross of Christ is reflected in every spring of water and stamped on every loaf of bread, that because of Calvary “the family board becomes as the table of the Lord, and every meal a sacrament” (27). The continued temporal existence of every human being—indeed, of the entire earthly creation—is due to the second trial Jesus procured for humanity by His death on the cross. 

But this is not the same as universal legal justification. A second trial is just that—a second trial. It is not the same as an acquittal. (Just ask the Menendez brothers and O.J. Simpson!)


The doctrine of universal legal justification is contrary to both Scripture and the writings of the Spirit of Prophecy.  In substance it is indistinguishable from the unscriptural doctrine of a finished atonement on the cross, with its hostile implications for such key Adventist doctrines as the sanctuary. (It should be noted here that when Ellen White speaks of a finished atonement at Calvary, as she does in a number of statements (28), she is speaking in context of a completed sacrifice, not legal salvation accomplished for the whole world.) Desmond Ford and his theological acolytes, during the final decades of the twentieth century, promoted this theory to fellow Adventists in such statements as the following:

My brethren, my sisters, Jesus Christ took away your sins, even yours, two thousand years ago. He was our Champion, He was our Representative, He was our Saviour. Everything He did is put to our account (29).

We were ruined by our first representative (Adam) and we had nothing to do with that.  The good news of the gospel is that we have been redeemed by our second Representative (Jesus Christ) and we had nothing to do with that either (30).

God forgave us 2,000 years ago, through the blood of His Son. And there is nothing we can do to earn or add to it. If you and I could make things right, by asking for forgiveness and making restitution, then Christ wouldn’t have had to die.  But He did! And with His death, “it is finished” (31).

It was on the basis of this teaching, among other things, that Ford offered the following denial of the final atonement in heaven beginning in 1844, thus challenging the unique contribution of Seventh-day Adventism to Christian thought as it is found in Scripture, the writings of Ellen White, and in classic Adventist theology. In Ford’s words:

Hebrews knows nothing of an “extended” atonement which drags on for 1,800 years after the cross. . . Every translation of these verses is plain that the cleansing of the sanctuary on the Day of Atonement by the Jewish high priest found its fulfillment in the cross of Christ, for on Calvary Christ put away sin by the sacrifice of Himself (32).

Logical discomfort between the doctrine of universal legal justification and the classic Adventist sanctuary doctrine has been amply demonstrated in recent decades within the Seventh-day Adventist Church. And the discomfort makes sense. If everyone’s sins were forgiven at the cross and everyone was legally saved then and there, both the investigation of character through the opening of heaven’s books (Ex. 32:32-33; Dan. 7:9-14; 12:1; Rev. 3:5) and the call to total victory over sin in preparation for Jesus’ coming (Zeph. 3:13; I Thess. 5:23; II Peter 3:10-14; I John 3:2-3; Rev. 12:17; 14:5,12) lose the constraint of the imperative. Salvation is abbreviated to the universal legal verdict of the cross, “plus nothing,” thus rendering any talk of a necessary sanctified response both superfluous and contradictory. The practical outcome of this teaching has been widespread personal and institutional disregard for the written counsel of God—the replacement by many modern and contemporary Adventists of a once-robust doctrinal and moral witness with doctrinal indifference, spiritual ambiguity, and moral vacillation.

In addressing the problem of Fidel Castro’s Cuba prior to the Bay of Pigs invasion of 1961, Senator J. William Fulbright, then serving as chairman of the U.S. Senate Foreign Relations Committee, advised the Kennedy administration: “The Castro regime is a thorn in the flesh, but it is not yet a dagger in the heart.”

The doctrine of universal legal justification is truly a dagger in the heart of Seventh-day Adventist theology, placing at risk both the sanctuary doctrine and the doctrine of complete triumph over sin on the part of believers this side of heaven. It is yet another variation on the unscriptural theme of effortless, too-easy salvation. As such, it merits unflinching opposition on the part of those adhering to the supreme authority of inspired writings in all matters spiritual.


1.  Jack Sequeira, Beyond Belief: The promise, the power, and the reality of the everlasting gospel (Boise, ID: Pacific Press Publishing Assn, 1993), p. 8.

2.  Ibid, p. 36.

3.  Ellen G. White, SDA Bible Commentary, vol. 6, p. 1070.

4.  ----Selected Messages, vol. 1, p. 390.

5.  ----Steps to Christ, p. 23.

6.  ----Selected Messages, vol. 3, p. 191.

7.  Ibid, vol. 1, pp. 393-394.

8.  Ibid, p. 366.

9.  ----The Upward Look, p. 49.

10.  ----Patriarchs and Prophets, p. 522.

11.  ----Selected Messages, vol. 1, p. 365.

12.  ----Manuscript Releases, vol. 13, p. 22.

13.  ----Thoughts from the Mount of Blessing, p. 114.

14.  ----Sons and Daughters of God, p. 182.

15.  ----The Desire of Ages, p. 821.

16.  ----Reflecting Christ, p. 146.

17.  ----Faith and Works, pp. 53-54.

18.  ----Signs of the Times, Jan. 20, 1881.

19.  ----Sons and Daughters of God, p. 238.

20.  ----Selected Messages, vol. 1, p. 343.

21.  ----Messages to Young People, p. 70.

22.  ----SDA Bible Commentary, vol. 4, p. 1159.

23.  ----Patriarchs and Prophets, p. 67.

24.  Ibid, p. 66.

25.  ----SDA Bible Commentary, vol. 7, p. 951.

26.  ----Faith and Works, p. 21.

27.  ----The Desire of Ages, p. 660.

28.  See Ministry of Healing, p. 451; Testimonies, vol. 6, p. 364; That I May Know Him, p. 73; This Day With God, p. 270; Review and Herald, Aug. 19, 1890; Sept. 24, 1901; Signs of the Times, June 28, 1899; Aug. 16, 1899).

29.  Desmond Ford, quoted by A. John Clifford and Russell R. Standish, Conflicting Concepts of Righteousness by Faith in the Seventh-day Adventist Church—Australasian Division (Clifford & Standish, Publishers, 1976), p. 82.

30.  ----Good News for Adventists (Auburn, CA: Good News Unlimited, 1985), p. 14.

31.  Steve Marshall, Blessed Assurance (Arroyo Grande, CA: Concerned Communications, 1979), p. 21.

32.  Ford, Good News for Adventists, p. 38.